Monday, January 7, 2013

New York Fracking Report Leaked to the New York Times

Last Thursday the New York Times reported that an
analysis on fracking prepared in early 2012 was leaked to their paper. This
analysis was prepared last year after the New York Department of Environmental
Conservation’s 2011 draft environmental impact statement (EIS) on drilling comment
period was closed and might have been prepared in response to the comments
received. The 8 pages obtained by the New York Times were characterized by the
paper as containing an analysis that showed that hydraulic Fracturing, or
fracking, could be safely done in New York by implementing the proper
mitigation measures. The report, obtained by the New York Times from and “expert
who did not believe it should be kept secret,” was characterized by State
Department of Environmental Conservation, DEC, as an out of date summary that
was nearly a year old and will undergo significant changes. The revised version
of the Environmental Impact Statement has not yet been completed or released
and the DEC’s health assessment is being reviewed by three outside experts. I
think someone may have violated the terms of their consulting contract.

The report (or summary) the New York Times had seems to
be in agreement with the recommendations made in the report of the Shale Gas Subcommittee of the Secretary of Energy Advisory Board in 2011. That report had
a rational approach to regulation recommending disclosure, testing, evaluation
and modification of regulation and practices based on the information and data
obtained. It assumes information and data will be gathered and analyzed and
seems to be the accepted view, but fracking is a highly complex issue whose
greatest risks are to our water resources. There needs to be much more data
collected over time and analyzed. That has not being done in the past and until
extensive data is collected and studied we will not truly know. The data needs
to be collected on a state by state basis and provided to the US Geological
Survey (USGS) and US EPA to consolidate on a national level. It is essential that the USGS be involved because of the unique expertise and research in geology and water resources.

In 2011, the EPA began a series of research projects into
the impacts and potential impacts of fracking on water that are scheduled for
completion in late 2014. These projects will be the basis of their actions and
future regulations for oil and gas operations. Whether the EPA will regulate
oil and gas exploration nationally or leave the oversight in the hands of the
states is an open question. There is an argument that water resources and
geology are very local phenomena and cannot be generalized over the nation and
that hydraulic fracturing should remain under local oversight. According to the
New York Times the leaked report rejects performing a quantitative risk
assessment because such an assessment would ‘involve making a large number of assumptions
about the many scenario-specific variables that influence the nature and degree
of potential human exposure and toxicity.”

The EPA research projects may help with that though all
the answers will not be known in 2014. The
current fracking projects at the EPA are a series of studies. Existing Data
from multiple sources have been obtained for review and analysis. Well
construction and hydraulic fracturing records provided by well drillers are
being reviewed for 333 oil and gas wells across the United States; data within
these records are being examined to assess the effectiveness of current well
construction practices at containing gases and liquids before, during, and
after hydraulic fracturing.

Computer models are being developed (or expanded) to
identify conditions that may lead to impacts on drinking water resources from
hydraulic fracturing. The EPA has created hypothetical scenarios for water
acquisition, well injection, and wastewater treatment and waste disposal stages
of the water cycle that they hope to have the models evaluate. Computer models
are also being used to explore the possibility of subsurface gas and fluid
migration from deep shale formations to overlying aquifers in different
scenarios. The effectiveness of the models would be dependent on how closely
the model predicts transport behavior in rock and shale and the similarity in
behavior of different formations.

Laboratory studies are being performed to identifying
potential impacts of inadequately treating hydraulic fracturing wastewater and
discharging it to rivers. Experiments are being designed to test how well
common wastewater treatment processes remove selected contaminants from hydraulic
fracturing wastewater, including brines, heavy metals, radionuclides and
organic contaminants. Since wastewater treatment plants are not designed to
remove more than biological waste and bacteria, any removal of fracking
chemicals and contaminants would be incidental.

The EPA has identified chemicals used in hydraulic
fracturing fluids from 2005 to 2011 and chemicals found in flowback and
produced water. The EPA is performing toxicity assessments based on chemical,
physical, and toxicological properties for chemicals with known chemical
structures and using exiting toxicology models to estimate properties in cases
where information is not available. The important thing that EPA is doing is
bringing together all the data and previous work to get as complete picture of
what we know about how hydraulic fracturing may be impacting our water
resources and that would allow a broad quantitative health risk assessment to be
performed along the identified routes of exposure.

New York placed a moratorium on drilling in the Marcellus
Shale in 2010 while it assessed the effects of fracking. New York DEC’s draft
environmental impact statement (EIS) on drilling was released in the fall of
2011 and recommended that drilling be permitted, but with conditions. The comment
period was extended and the DEC began a revision to the EIS that has been going
on for over a year. The leaked report indicates that the DEC is recommending
lifting the ban on hydro fracking in New York, but that is not certain and
fracking remains controversial for good reason.

A large swath of southwestern New York sits atop the
Marcellus Shale, which is the third-largest natural gas field currently known
in the world. The Marcellus Shale alone is estimated to be
500-trillion-cubic-feet of gas reserve. This resource could heat our homes for
a generation or more, and power our electrical generating plants, even fuel
cars either directly or through plug in hybrids. The possible impacts to our
economy and environment are far reaching. The potential risks are also far
reaching.

Our ability to recover natural gas buried a mile or more
beneath the earth has increased. Advances in horizontal drilling which allows a
vertically drilled well to turn and run thousands of feet laterally through the
earth combined with advances in hydraulic fracking, the pumping of millions of
gallons of chemicals and water into shale at high pressure have increased our
ability to recover natural gas from shale. Hydraulic fracking while old has
made tremendous advances in the past 15 years have made it possible to
economically access this gas. Our knowledge of the impacts from fracking has
lagged behind our ability to access the gas.

In hydraulic fracking on average 2-5 million gallons of
chemicals and water is pumped into the shale formation at 9,000 pounds per
square inch and literally cracks the shale or breaks open existing cracks and
allows the trapped natural gas to flow. Each stage of the fracking water cycle
is a potential area for impact to drinking water supplies especially from human
error and irresponsibly and improperly handling chemicals and contaminated
water and poorly managing and protecting our water resources. Water used for
fracturing fluids is acquired from surface water or groundwater in the local
area. Billions of gallons of water will be used in each region for fracking. Wastewaters
from the hydraulic fracturing process (flowback or water produced in the well) needs
to be properly treated before it is returned to the waters of the earth. The
reality is all water on earth has been here for 4.5 billion years and no new
water is being created. The fate of the water that flows back after fracturing has
to be addressed, but not all fracturing fluids injected into the geologic
formation are recovered. The EPA estimates that the fluids recovered range from
15-80% of the volume injected depending on the site. The long term fate of
any residual fluid has not been studied.

There have been
documented cases of seepage into drinking water wells through improperly sealed
or abandoned drilling wells. An ongoing
monitoring and data collection program needs to be part of the permitting
process. Potential impacts to our water supply from hydraulic fracking needs to
be studied over time and regulations modified to better protect our water
supplies and natural resources as fracking expands in the region. Our water
resources are sacred and irreplaceable. The gas will be there when we know how
to access it safely. The least risky course
might be to delay lifting the moratorium until the US EPA finishes its research
in late 2014 and then slowly allow a limited number of wells that will include
monitoring over decades of the groundwater resources in the area with all the
data given to the USGS for analysis. Any
area in consideration for fracking should have several years of quarterly
groundwater testing and analysis before fracking begins to establish a base
line for groundwater study. Now would be a good time to start developing
groundwater monitoring programs.

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Elizabeth Ward

About Me

Elizabeth was awarded an MBA from the University of Pittsburgh and an MS ChE from Polytechnic Institute of NYU, worked as a chemical engineer for both the US EPA in DC, and at DuPont before working in finance and then becoming consultant with Washington Advisors and is the author of "The Lenders Guide to Developing an Environmental Risk Management Program." Elizabeth retired from Washington Advisors and began her volunteer career and is currently the Treasurer of the Prince William Soil and Water Conservation District.

Purpose

Green Risks provides information to understand the natural world especially in our local region. The blog is a mix of technical guidance and interesting information with a slant towards information to live a greener and more sustainable life. You will find articles on a wide range of water and environmental topics including help with water well problems and maintenance, septic systems and regulations, solar energy, low impact development, and many others all with the intent of teaching practical ways to solve problems and revive common sense in our society.